These comments are submitted by the Virginia Pest Management Association (VPMA).  VPMA, in operation since 1948, is the trade association for pest management companies in Virginia.  VPMA represents 225 pest management companies in Virginia. The mission of VPMA is to safely protect the health and property of the Commonwealth’s general public by promoting ethical and environmentally responsible business and pest management practices among our members through education, coalition and professionalism.

VPMA urges the Board of Agriculture and Consumer Services to deny the Coake petition for rulemaking.  The petition is redundant in stipulating a specific punishment for not obtaining written permission from the property owner and not providing notification because the Virginia Pesticide Control Act includes administrative process to penalize licensed pesticide applicators for non-compliant applications.  The penalty matrix includes fines, applicator and pesiticide business license suspension and revocation as options.